ML17296B318
| ML17296B318 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 03/24/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17296B317 | List: |
| References | |
| NUDOCS 8104020913 | |
| Download: ML17296B318 (84) | |
Text
220-1 220.0 220.1 STRUCTURAL ENGINEERING BRANCH Provide information on any underdrains or pressure relieving systems (3:4 2) used at the Palo Verde station.
220.2 Provide information on the strain levels of soil during an OBE and
- SEE, and the variations of soil strain with the depth and layering of the supporting soil media.
Oescribe the procedure of using strain-dependent soil properties (damping and shear modulus) to model the soil-structure interaction system.
To what extent is the computer program, SHAKE used to develop strain-corrected damping values for foundation materials and what is the theoretical basis for such use?
220.3 (3.7.2)
Explain why each of.the Category I structures (containment building, auxiliary building, control building, and fuel building) have different f
sets of natural frequencies for OBE and for SSE.
Do the natural fre-quencies listed in tables 3.7-3 through 3.7-6 represent the structural modes only, or the soil-structure interaction modes as well?
r 220.4 Supply, for each mode of vibration listed in tables 3.7-3 through 3.7-6, (3.7.2) the mode shape and its corresponding participating factor:
220.5 'erform a comparative study of structural response results obtained (3.72) by two different approaches of soil m'odeling to soil-structure inter-action analyses:
the half-space method (lumped parameter, compliance
IQ
220-2 function or im
, or impedance function methods}
and the finite boun-.
r an e
ini e
oun-..~r method (also
(
so known"as the finite element,'hear beam or one-dimensional shear wave methods).
g o
s guantities to be compared should include flfloor response spectra in typical Category I
structures; e..
.g. at the basemat, operating floo d
oor an an upper elevation of the containment building, and at the basem nt and an intermediate elevation of the au '1' auxi iary building.. The input ground motion or con control motion should be applied at the foundation level as el as required by Appendix A to 10CFR100.
220.6 Provide the specific number of, earthquake cycles used in the design (3.7.3) of subsystems of the Palo Yerde Station.
The Standard Review Plan 3.7.3 t
s ates that postulatina one safe shutdown earthouake I
and five operating basis earthquakes with ten stress cycles per earthquake is acceptable.
220.7 (3.7.3)
The criteria for combining responses of three components'of earthquake motion have been stipulated in Regulatory Guide 1.92.
The criteria suggested in NUREG/CR 0098 are for certain operating plants only and have not been approved for use at the Palo Yerde station.
The applicant -should either provide justification for using the NUREG/
CR 0098 criteria or commit to using R. G. 1.92 criteria for the Palo Verde seismic analysis.
220.8 The acceptance of the topical report BC-TOP-5A's a reference for (3.8.1) prestressed concrete nuclear reactor containment structures
. ~
220-3.
'xcludes its applicability to subsection 3.8.1.6, t/aterials 1
guality Control and Special Construction Techniques.
Identify, all deviations frdm PSAR commitments and all exceptions to accepted codes.
Provide explanation and justification for these deviations and exceptions.
220.9 (3.8.3 3.8.4}
Identify any deviations from the PSAR design cri teria used for Category I
structures and any exception to applicable accepted codes.,
Provide explanation and.justification for these deviations and.
exceptions.
220. 10 Are there any concrete masonry walls used in any of the Category (3.8.4}
I structures of the Palo Yerde plant?
If there are, provide answers to the following questions:
(a}
Indicate the loads and load combinations which the walls are designed to resist.
If load factors other than one (1.0}
have been. employed, indicate their magnitudes.
(b)
In addition to complying with the applicable requirem nis of the SRP Sections 3.5, 3.7 and 3.8, is there any other code such II as the Uniform Building Code" or the "Building Code Requirements for Concrete Nasonry Structures" (proposed by the American Concrete Institute) which was or is being used to guide the design of these walls?
Please identify and discuss any exceptions or deviations
~ 4 JI from the SRP requirements or the aforementioned codes.
220-4 (c)
~ Indicate the method that you used to calculate the dynamic forces in masonry walls due to earthquake, i.e., whether it is a code method such as Uniform Building Code, or a dynamic analysis.
Identify the code and its effective date if the code method has been used.
Indicate the input motion if a dynamic analysis has been performed.
(d)
How were the masonry walls and the 'piping/equipment supports 4
attached to them designed?
Provide. enough (numerical) examples including details of reinforcement and attachments to illustrate the methods and procedures used to analyze and design the walls, t
and the anchors
'needed for supporting piping/equipment (as applicable).
(e)
Provide plan and elevation views of the plant structures showing the location of all masonry walls for your facility.
~
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~
~
, 260-1 260.0 UALITV ASSURANCE 260.1.
.(17.2.0) 260.2.
(17.2.'1) 260.3.
(17.2.1 13.1,.1) 260.4.
(17.21.
13.1.1) 260.5.
(17.2.2)
Provide a statement that the responsibility for the PVHGS QA program is retained and exercised by APS during the operations phase.
Identify and describe any major delegation of-work involved in establishing and implementing the QA program for the operations phase of the PVNGS.
Section 17.2.1.1.2 of the FSAR indicates that the Operations Executive Vice President is.responsible for procurement.
Figure 13.1-2 shows no procurement organization, and the FSAR does not describe the QA responsibilities of a pro-curement organization.
Clarify.
Figure 13.1-4 shows a Site Quality Assurance Supervisor and Site Quality Assur-ance Personnel reporting to the Quality Assurance Manager.
These site person-nel are not shown on Figure 17.2.1, and page 17.2-9 indicates the Quality Assur-ance Departmert is organized into but two sections.
Clarify.
Also, discuss the need of the QA Manager to have some full time onsite staff in order to
'erify effective implementation of the Corporate Operations QA Program.
Section 17.'2.2.2.2 states:
"Quality verification'is the basic responsibility of the organization or group performing the activity." Actually the organiza-tion or group performing a quality-related activity (Maintenance, Engineering, Operation, Procurement, etc.)
should be responsible for the activity resulting in a quality product, and verification should be the responsibility of an "independent" organization.
Discuss the separation of responsibilities by organization for performance of the work activities and for performance of quality control (quality veri.fication)'.
260.6.
Clarify that the minimum qualification requirements for the Quality Assurance (17.2.1)
Manager include a) management experience and b) the requirements of Section 4.4.5 of ANSI/ANS-3.1-1978 as endorsed by Regulatory Guide 1.8.
'260.7.
(17.2.1) 260.8.
(17.2.2) 260.9.
(1'7.2.2)
Identify (by position title) the person responsible for the onsite QA Program.
The individual in this position should be free of non-QA duties such that he can give full attention to assuring that the QA program at the plant site is being effectively implemented.
Section 17.2.2.3 addresses implementation of the operational QA program.
Pro-vide therein a commitment that the QA program for operations will be imple-mented at least 90 days prior to fuel loading.
Provide a commitment that the QA program will be applied to the development,
- control, and use of computer programs and describe its application.
'fable 17.2-1 indicates that the Fire Protection QA Program is. met as part of the QA Program under 10 CFR Part 50, Appendix B.
Item 16 in Table 3.2-1 of the FSAR indicates that the PVNGS QA Program does not apply to the fire pro-tection system.
Clarify.
'N V
26n 2 260.11.
(17.2.2) 260.12.
(17.2.2) 260.13.
(17.2.2 i 1.8)
Provide a commitment that special equipment, environmental conditions, skills, and processes will be provided as necessary.
Provide a commitment to notify the NRC (cc:
gA Branch) of a) changes to the gA program prior to implementation and b) orgapizational changes within 30 days after announcement..
(Note that editorial changes and personnel reassign-ments which are not substantive need not be reported.)
The following items refer to APS's position on gA-related regulatory guides and standards:
(1)
Regulatory Guide 1.28 - Commitment should be to Revision 3, February 1976.
(2)
Regulatory Guide 1.29 - Commitment should be to Revision 3, September -.-
1978.
(3)
Regulatory Guide 1.30 - Reference to the Bechtel quality program for construction should be deleted.
(4)
Regulatory Guide 1.33-(a)
Exception 1 is unacceptable.
It is the staff position that pro-posed changes to technical specifications or license amendments be reviewed and approved by the independent review body prior to submittal to the NRC for approval.
(b)
The interpretation regarding Section 5.2.2 of ANSI N18.7 is acceptable providing the other requirements of Section 5.2.2 are met.
(c)
The interpretation regarding Section 5.2.17 of ANSI N18.7. is acceptable with the under standing that all deviations areMocu-mented and corrected.
(5)
Regulatory Guide 1.37 - Reference to the Bechtel position during construc-tion should be replaced by the APS position for comparable activities during the'operations phase.
(6)
Regulatory Guide 1.38-(a}
Commitment should be to Revision.2, Hay 1977.
(b)
Same as (5) above..
(7)
Regulatory Guide 1.39 - Same as (5) above.
(8)
Regulatory Guide 1.58 - Commitment should be to Rev. 1, September 1.980.
Il f (9)
Regulatory Guide l.64-(a)
Commitment should be to Revision 2, June 1976.
(b)
Same as (5) above.
260-3 260.14.
(17.2.2) 260.15.
(17.2.2) 260.16.
(17.2.2)
(10)
Regulatory Guide 1.88 - Comnitment should be to Rev. 2, October 1976..
/
(11)
Regulatory Guide 1.94 - Include APS Position on Rev. 1, April 1976.
(12)
Regulatory Guide 1.116 - Include APS Position on Rev.
O-R, flay 1977.
(13)
Regulatory Guide 1.123 - Include APS Position on Rev.
1, July 1977.
(14)
Regulatory Guide 1.144 - Include APS Position on Rev. 0, January 1979.
(Note that this Reg.
Guide references ANSI N45.2.12-1977 as listed in Tab'le 17.2-1.)
(15)
Regulatory Guide 1.146 - Include APS Position on Rev. 0, August 1980.
(Note that this Reg.
Guide, references ANSI N45.2.23-1978 as listed in Table 17.2-1.)
The last sentence of Section 17.2,2.4 indicates that Appendix 17B is a cross-reference of Appendix B to 10 CFR Part, 50 and procedures in the Corporate Opera-tions gA Manual.
This is not what Appendix 178 contains, and it appears the reference should be to Table 17.2-2 on page 17.2-35 of the FSAR.
Clarify.
Describe how responsibilities and control of quality-re'lated activities are transferred to APS during the phaseout of design and construction and during preoperational testing and plant turnover.
In Section 17.2.2.9, "Personnel Indoctrination and Training," provide commit-ments that (1)
Personnel, responsible for performing,quality-affecting activities are instructed as to the purpose,
- scope, and imp'lementation of the quality-related manuals, instructions, and procedures.
(2)
Personnel verifying activities affecting quality are trained in th p inciples, techniques, and requirements of the activity being performed.
r i
e
(
)
Proficiency of personnel performing and verifying activities affecting quality is maintained by retraining, reexamining, and/or recertifying as determined by management or program commitment.
260.17.. Describe measures which assure that plant personnel are made aw re t'
(17.2.3).
ba i duties.
(.. ).
asis of design changes/modifications which may affect the performance of th
'ware on a
mme y ce o
eir 260.18.
(17.2.3) 26O.19.
(17.2.3)
The last paragraph in Section 17.2.3 commits APS to take action to prevent recurrence of errors or deficiencies in the design process.
Include a comnit-ment te a15o correct al 1 such errors or deficiencies.
kSCr'ibe how APS differenti'ates between design documents which require formal esign review by interdisciplinary or multi-organizational teams and those
'f which can be reviewed by a single individual.
Provide a list of typical exampl each.
Include such documents as specifications, calculations, computer xamp es
260-4 260.20.
(>>.2,3) 260.21, (17.2.3) 260.22.
(17.2.3) 260.23.
(17.2.4)
- programs, system descriptions, SAR when used as a design
- document, and drawings including flow diagrams, piping and instrument diagrams, control ogic diagrams,,electrical single line diagrams, structural systems for major facilities,.site arrangements, and equipment locations.
Clarify whether the'responsibilities of the verifier, the areas and features to be verified, the pertinent considerations to be verified, and the extent of documentation are identified in procedures.
Describe measures which assure that the following provisions are included if a design or a design feature is verified by test:
(1)
Procedures provide criteria that specify when verification should be by test.
(2)
Prototype, component or feature testing is performed as early as possi-ble (i.e., prior to installation of plant equipment).
(3)
The tests simulate the most adverse design conditions as determined b
analysis.
e ermine y
Describe measures which assure that only verified computer codes are certified for use and that only certified computer codes are used for design.
Identify the APS organization(s) responsible for (1) procurement planning; (2) the preparation, review, approval, and control of procurement documents; (3) supplier selection; (4) bid evaluations; and (5) review and concurrence of supplier gA programs prior to initiation of activities affected by the program.
Describe the involvement of the. Nuclear guality Assurance organization in these activities.
260.24.
(17.2.5)
Section 17.2.5 indicates the PVHGS guality Section reviews and concurs with instructions, procedures, drawings, etc. which govern safety-related work at the site.
Verify that this review determines; the need for inspection, identification-of inspection personnel, and documentation of inspection results; that the inspection requirements,
- methods, and acceptance criteria are identified.
260. 25.
(17.2.7)
To the list of documents in Section 17.2.6, add "as-built" docume tat I-Cicate vhi
'i ch of the doc~nts on the list are reviewed and concurred with by ocumen aon.
n-
260-6 the QA organization with regards to QA-related aspects.
260.26.
Oescribe how APS assures that obsolete and superseded documents are removed and (17.2.6) replaced by applicable revisions in work areas in a timely manner.
260.27.
(1?.2.6) 260.28.
(1?.2.7) 260.29.
(17.2.7 i 17.2.4) 260.30.
(17.2.7)
Oescribe the document control system established by APS (Is a master list routinely updated and distributed to responsible personnel?)
which identifies the applicable revision of instructions, procedures, specifications,
- drawings, and procurement documents.
Section 17.2.7.2 states that surveys made by third parties such as. CASE may be used to evaluate a potential supplier.
-Prbvide a commitment that, when such surveys are used, documentation identifies the survey used and provides evidence of review of the survey and its results by APS Quality Assurance.
The last paragraphs of Sections 17.2.4.3 and 17.2.7.1 both address controls for the procurement of spare or replacement parts.
It is not clear that these pro-curements are subject to the latest QA program controls and to codes, standards, and technical requirements equal to or better than originally imposed or as required to preclude repetition of defects.
Clarify.
Regarding receiving inspe'ction:
(1)
The last sentence in 17.2.7.4.1 states:
"Receiving inspection will be conducted prior to release of items for installation or storage."
Change "conducted" to "completed" as this makes the sentence compatible with the last sentence of 17.2.7,.5.
260.31.
(17.2.?)
(2)
Section 17.2.7.5 does not make it clear that items are not installed or.
used prior to supplier/contractor documentation being available at the site.
Clarify.
The last sentence of 17.2.7.4.2 places the responsibility for selecting the measures to be used for acceptance of "services only" contracts with the organi-zation responsible for the procurement action.
t1ake QA a party to such decisions or justify not doing so.
260.32.
Oescribe how APS evaluates the validity of suppliers'ertificates of conformance.
(17.2.7) 260.33.
(17.2.8) 260.34.
(17.2.9) 260.35.
(17.2.9) 260.36.
(17.2.10)
Oescribe measures which assure the verification of correct material, parts, and components immediately prior to installation.
Provide a more nearly complete list of processes that are controlled as special processes by APS.
Ideft4<<g M APS organizations. involved in qualifying special processes used at PYf45 and describe the responsibilities of each.
Oescribe measures which assure that when inspections associated with normal operations o
the pla'nt (such as routine maintenance, surveillance,:and tests) are performed by individuals other than those who performed or directly super-vised the work, but are within the same group, the following controls are met:
B' VI
260-6 260.37.
(17.2.1 0) 260.38.
(17.2.10)
(1)
The quality of the work is demonstrated through a functional test when the activity involves breaching a pressure retaining item.
(2)
The inspection procedures, personnel qualification criteria, and indepen-dence from undue pressure such as cost and schedule are reviewed and found acceptable by the OA organization prior to initiating the inspection.
Describe measures which assure that a qualification program for inspectors is established and documented, and the qualifications and certifications of inspec-tors are kept current.
Expand the list of items included in inspection procedures, instructions, and checklists on page 1.7.2-46 to include (1)
Identification of applicable procedures,
- drawings, and specifications and revisions.
260. 39.
(17.2'.10) 260.40.
( 17.2.>> )
(2) 'Identification of the required measuring and test equipment.
Describe how APS assures that inspection results are documented, evaluated, and their acceptability determined by a responsible individual or group.
Section 17.,2.11 at the top of page 17.2-50 states regarding test control that administrative procedures "will be developed and implemented...."
Provide a
schedule.
260.41.
Identify the APS organizations involved in establishing, implementing, and (17.2.12) assuring effectiveness of the PVNGS calibration program-,
and describe the responsibilities of each.
260.42.
(17,2.12) 260.43.
,'17.2.l3) 260.4'4.
(17.2.15) 260.45.
17.2.15)
Provide a commitment that calibration of measuring and test equipment is against standards that have an accuracy of at least four times the required accuracy of the equipment being calibrated or, when this is not possible, have an accuracy that assures the equipment being calibrated will be within required tolerance and that the basis of acceptance is documented and authorized by responsibl m nagement.
Also provide a commitment'hat'alibrating standards have greater a
e accuracy than standards being calibrated..-(Calibrating standards with the sam accu acy may be used if.it can be shown to 'be adequate for the requirements a
d r
e same
'th e basis of acceptance is documented and authorized by responsible management.)
n Describe provisions for the storage of chemicals, reagents (including control of shelf life), lubricants, and other consumable materials.
Identify the organizations which have the authority and responsibility to identify nonconformances, to disposition nonconformances, and to independentl f evie( nonconformances, their disposition, and closeout.
Describe in more n
y detail the APS nonconformance control procedure.
Clarify that nonconformances will be corrected or resolved before beginning'reoperational testing of the nonconforming items.
0
260-7
. -260.46.
(17.2. 16) 260.47.
(17.2'.16) 260.48.
(1?.2.17) 260.49.
(17.2.18)
Part 17.2.16 uses the expression "conditions adverse to quality" throughout.
In part 17.2.16 or in Appendix B, define what this expression means.
Also describe the directions provided to aid in the determination of whether or not a "condition adverse to. quality" is significant.
Describe measures which assure that corrective action is taken and closed out in a timely manner.
Identify the organization(s) under the Plant Manager responsible for imple-menting activities related to gA records.
Clarify that a~dit schedules are routinely updated to reflect status, that audit schedules include the audits conducted by the PVNGS (}uality Section, and that results of audits conducted by the PVNGS guality Section are provided to the guality Assurance Department for review and assessment.
/
281-1 281.0 281.1 (6.i.l, 6.5.2) 281. 2 (g.i.3) 281.3 (9.3.2 and Action Plan I!.8.3) 281. 4 (6.1.2)
CHEMICAL ENGINEERING BRANCH In the FSAR you indicated that, following an accident which requires
'peration of the containment. spray
- system, hydrazine will be used in the spray water for short-term injection and trisodium phosphate will be added to the sump water for long-term recirculation.
In view of the fact that trisodium phosphate has a tendency to cake, it may not be readi ly dissolved in the sump water following the accident.
Prov ide design basis information and a proposed sur-vei llance program to ensure that by commencement of the recircula-tion of sump water, sufficient trisodium phosphate will be dissolved in the sump water to achieve a
pH value of at least 8.5.
For the fuel pool cleanup
- system, indicate that chemical analyses /
at least weekly and continuous radiological monitoring will be made for measuring the efficiency of,the filters and ion exchange resins to remove. impurities and radioactive materials from the pool water.
State what criteria (chemical parameters, decontamination
- factors, etc.)
will be used to determine replacement of the filters and ion exchange resins.
,Describe the provisions to meet the requirements of post-accident sampling of the primary coolant and containment atmosphere.
The description should address all the requirements outlined in Section II.B.3 of Enclosure 3 in NUREG-0737 (Clarification of TM! Action Plan Requirements) a'nd should include the appropriate P 5 ID's.
In addition, if gas'hromatography is used for reactor coolant analysis, special provisions (e.g.,
pressure relief and purging) should be provided to prevent high-pressure carrier gas from entering the reactor coolant.
With respect to clarification (4) in Section II.B.3 of NUREG-0737, if the chloride concentration in the reactor coolant samples exceeds the limit in the Technical Specification, oxygen analysis wi 11 be mandatory.
Provide also either (a) a summary description of procedures for sample collection, sample transfer or transport, and samp'le analysis,
.or (b) copies. of procedures for sample collection, sample transfer or transport, and sample analysis.
Indicate the total amount of protective coatings, paints,. and organic materials (including uncovered cable insulation) used inside the containment that do not meet ANSI N101.2
( 1972) and Regulatory Guide 1.54;
282-1 282.0 282. 1 (9.1.2 3)
.282.0 CHEMICAL ENGINEERING BRANCH Provide fabrication details of the Boral tube inserts to be used in the spent fuel storage pool.
Provide details of the kind and thickness of the cladding of the Boral.
Explain how exposed Boral.matrix (Boron carbide) is protected from the borated pool water.
Describe the corrosion protection of the Boral tube.
282.2 Provide the steam generator secondary water chemistry control and
( 10.3.5) monitoring program, addressing the following:
7 1*.
Sampling schedule for the critical parameters and of control. points for these parameters for each mode of operation:
normal operation, hot.startup, cold startup, hot shutdown, cold wet layup; 2.
Procedures used to measure the values 'of the critical parameters; 3,
Process sampling points; 4.
Procedure for the recording and management, of data; 5
Procedures defining corrective actions* for off-control point'hemistr
~
conditions; and oin emis ry 6.
The procedure identifying (a) the authority responsible for th t
p o
of the data and (b) the sequence and timing of administrative retati n
e in er-.
events required to initiate corrective action.
Verify that the steam generator secondary water chemistry control program incorporates technical recommendations of the NSSS.
Any significant deviations from NSSS recommendations should be noted and justified technically.
In addition to the secondary water chemistry monitoring and control program, d n a
.we require monitoring of the steam condensate at the effluent of the e
s te pump; The monitoring of the condensate is for the purpose of e con-detecting condenser leakage.
'Branch Technical Position YiTEB 5-3 describes the acceptable mean f mo 1
. n toring secondary side water chemistry in PMR steam generators, including corrective actions for off-control point chemistry conditions H
ih taf f is amenable to alternatives, particularly to Branch Technical Position B.3.b(9) of tiTEB 5-3 (go-hour time limit to repair or plug confirmed condenser tube leaks}.
U
430-1 430,0 POWER SYSTEMS BRANCH 430.1 (8.3)
Provide a detailed discussion (or plan) of the level of training proposed for your operators, mafntenance cree, qualfty assurance, and supervfsory personnel responsfble for the operatfon and maintenance of'he emergency dfese1 generators.
Identffy the number and type of personnel that Wll be dedicated.to the operations and maintenance of the emergency dfesel:
generators and the number and type that <11 be assfgned from your general p1ant operatfons and mafntenance groups to assfst shen needed.
Tn your discussion fdentffy the amount and kind of trafnfng that wfll be received by each of the above categories and the type of ongoing trafnfng program planned to assure optimum avaflabflfty of the emergency generators.
A1so dfscuss the level of educatfon and efnfmum experience requfr ements for the various categorfes of operatfons and mafntenance personnel assocfated.
fifth the emergency dfesel generators.
430. 2 perfodfc testfng and test 7oadfng of. an emergency dfesel generator fn a nuclear pomr plant fs a necessary functfon to demonstrate the (RSP}
operabflfty, capabfltty and avaflabflfty of the unft on demand Perfodfc testing coupled Rth good preventfve mafntenance practfces vill assure optimum equipment readiness and avaflabflfty on demand.
Thfs fs the desired goal.
To sc,'<eve th5s optimum equfpment readfness status the the follo~<ng r
requirements should be set;
V W
\\
r l
'430-2
\\
'h'.
The equipment should be tested 4th a minimum loading of 25 percent of rated load.
No load or light load operation will.cause Incomplete combustion of fuel resulting in the formation of gum and varnish deposits on the cylinder walls, intake and exhaust valves, pistons and piston rings, etc.,
and accumulat)on of unburned fuel fn the
\\
turbocharger and exhaust system.
The consequences of no load or light load operation are potential equipment failure due to the gum and varnish deposits and f1re )n the engine exhaust system.
2.
periodic surveillance'testing should be performed in accordance 4th the applicable HRC guidelines'(R.G.
1.108),
and Hth the, recommendations of the engine manufacturer.,
Conflicts between any such recomnendat$ ons and the NRC guidelines, particularly with respect to test frequency, loading and duration, should be ident'ied and )ustified, 3.
preventive maintenance should ~ beyond the normal routine aQust-
- eents, servicing and repair of components when'a malfunction occurs.
Preventive maintenance should encompass investigative testing of components which have a history of repeated malfunctioning and require constant attention and repatr.
In such cases consideration should be given to replacement of those components with. other products which'have a record af denonstrated relfab/ltty, rather than repetitive repair and maintenance'of the existing components, Testing Of the unit after adjustments or repairs have been made only confirms Chat the equipment fs operable
'and does not necessar)ly mean that the root cause of the problem has been el1minated or allev)ated.
I t
V t
430-3 a
Upon completfon of repafrs or Nafntenance and prfor to an actual start, run, and load test a ftnal equfpment check should be made to assure that a11'electrfcal cfrcufts are functfona1, f.e,, fuses are fn
- place, swftches and cficuft breakers are fn thefr proper posftfon, no loose wfres, all test leads have been
- removed, and all valves are fn the proper posftfon to permft a manual start of the equfpment, After the unft has been satfsfactorfly startea and load tested, return
%he unft to ready automatfc standby servfce and under the control of the.
control room operator.
Provfde a dfscussfon of how the above requfrements have been fmplemented fn the emergency dfesel generatr i "ystem desfgn and how they wfll be consfdered when the plant fs fn commercfal operatfon, f,e., by what means wfll the above requfrements be enforced.
430.3 The avaflabflfty on demand of an eqergency'dfesel generator fs (8.3)
RSP dependent
- upon, among other thfngs,'the proper functfonfng o1 fts controls and nenftorfng fnstrumentatfon, 's equfpment fs general'ty panel sounted and fn some fnstances the panels are pounted dfrectly
. on the dfesel generator
- sktd, Q$ot dfesel engfne damage has occurred at some operatfng plants from vfbratfon fnduced wear on skfd mounted control and monftorfng fnstr umentatfon.
Thfs sensftfve fnstrumentatfon fs not made to wfthstand and function accurately for prolonged perfods under contfnuous vfbratfonal stresses normally encountered wfCh fnternal combustfon
- engfnes, Operatfon'f'enstfve fnstrumentatfon unde~ thfs envfronment rapfdly deterforates calfbratfon, accuracy and control sfgnal output.
<v I'
1, g C,,
a
430-4 Therefore, except for sensors and other equipment that est be. directly counted on the. engine or associated pipfng, the contro1s and monitoring instrumentation shou1d be installed on a free standing floor munted panel, separate from the engine skids, and 1ocated on a vibration free floor area.
- If the floor is not vibration free, the panel shall be equipped with vibration mounts.
Confirm your compliance-with the above requirement or provide justification for noncompliance.
430,4 The
$ nforaat$ on regarding the onsfte amanfcitfons syste (~
(9,5.2) on 9.5.2) does not; adequately cover the systea capabilities cfuRng trans'fents and accidents.
provide the fo11cartng
$nformtfon:
(a)
Identify all irking stations. cn the plant s5te Here 4t aay be necessa~
'for plant pe'rsonnel to emaunfcate with the control roce or the energency shutdarn panel durfng an4'or following transients and/or 'accidents (tncluding f$res) tn order to mitigate the consequences of the event and to attain a safe cold plant shu~.
(b)
Indicate the max<amm sound levels that'ould exes at each.
of the above Identified working stat$ ors for all transients Chal accident conditions.
430-5 (c)
Indicate the es types of ccemun$ catfon systems available at each of the above
$ dent1f$ ed mrk3ng stations.
(d)
Indicate the saxfaua background 1
groun no se level that could exfst at each mrkfn sta g
tfon and yet rel<ab1y expect effective emaunfcat$ on wrath the control man using.
1.
the page party canmunfcaNons
- systems, and 2.
any other addftfona1 ccaaa
'h ccaaan<cat$ on system provided that mrk$ ng statfon.
{a)
Desert be the performance requirements d
an tests that the above ons$ te hark irking stations ccaaun$ cation systems wall be required to pass fn order to be assured that effective panel fs possible under all conditions.
(f) Identff and de y
d describe the ~r source{s) prodded for each
. of the cccmunf canons systems.
{g}
Discuss the protective measures taken to assure a functionally operable ons$ te ccamun$ cat$ on system.
The d$ scuss$ on should Include the cons5derat$ ons given to component failures, loss of power, and the severing of a comnunfcatfon line or trunk N a re ult of an accident or fire;
430-6
.430. 5 (9.5.3)
Identify the vital areas and hazardous areas where emergency lighting is needed for safe shutdown of the reactor and the evacua-tion of personnel in the event of an accident.
Tabulate the light-ing sy tern provided in your design to accormbdate those areas, so identif dentified.
Include the degree of compliance to Standard Review Plan 9.5.1 regarding emergency lighting mquirements in the event of a fire.
430. 6 Describe th be the instruments, controls, sensors and alarms provided for monitoring the diesel engine fuel oil storage and transfer system and describe their function.
Discuss the testing necessary to main-tain and assure a highly reliable instnmentation,
- controls, sensors and alarm system and where the alarms are arnunciated.
Identify the temperature, pressure and level sensors
~hich alert tte operator when these parameters exceed the ranges reccemended by the engine manufacturer and describe what operator actions are rendu)red durino alarm conditions to prevent harmful effects to'the diesel engine.
Discuss the system interlocks prcvided.
(SRP'- 9.5.4, Part III, item lj.
430-7 430.7 The dfese1 generator structures are desi g d to tornado criteria and are iso1ated from one another by a refnforced concrete wall barrier.
Oescribe the barrier (including openings) in more detail and its capability to withstand the effects of internally generated missiles resulting from a crankcase explosion, failure of one or'll of the starting air receivers, or failure of any high or moderate energy line and inftfal flooding from the cooling system so that the assumed effects will not result fii 1oss of an additional generator.
(SRP 9.5.4, Par. III, Item 2};
43(},8 Gescrfbe your design provisions Wade to protect th fu 1
f1 to (9.5.4) e e
o s
rage tank fill and vent lines from damage by tornado mfssf les.
(SRP 9.5.4, Part II).
430.9 Gfscuss the means for detecting or preventfng grow:h of algae fn (9.5. 4) the diesel fuel storage tank. If it were detected, describe the methods to be provided for cleanfng the affected storage tank.
(SRP 9.5.4, Part III, Itsa 4).
430-8 430.10 In section 9.5.4.2.1 you state that the diesel fuel oil storage tanks (9.5.4) are protected from co'rrosion in accordance with recommended practice "Control of External Corrosion on Underground or Submerged Piping Systems,"
RP-01-69 as published by the National Association of Corrosion Engineers.
This statement is incomplete; it does not discuss the buried piping or internal corrosion of the storage tanks due to water in the fuel oil.
Expand the FSAR to include a more explicit description of proposed pro-tection of underground piping. 'here corrosion protective coatings are being considered (piping and tanks). include additional industry standards which will be used in thei~ appl'.cation.
Also discuss what provisions will be made in the design of the fuel oil storage and transfer system in the use of a impressed current type cathodic protection
- system, in 'addition to water-proof protective coatings, to minimize corrosion of buried piping or equipment.
If cathodic protection is not being considered, provide your justification..
(SRP 9.5.4, Part II,. and Part III, item 4).
430.11 (3 2)
(9.5.4)
(.9.5.5)
(9.5.6)
(9.5.Z)
(9.5.8)
The FSAR text and Table 3,2-1 states that the components and piping systems for the diesel generator auxiltaries. (fuel oil system, cooling water, lubrication', air starting, and intake and combustion system) that are mounted on the auxiliary skids are designed seismic Category I and'are ASIDE Section III Clas's.
3 quality.
The engine mounted components and piping are designed and manufactured to DEMA standards, and are seismic Category I.
This is not in:
accordance with Regulatory Guide 1,26 which requires the entire diesel gentrttor huxiliary systems be designed to ASIDE Section III Class 3 or gu8fi.y't'oup C.
Provide 'the industry standards that were used.'in the
- design, manufacture, and inspection of the engine mounted piping 'and componen s.
Also show on the appropriate PAID's where the guality Group Classification changes from guality Group C,
430-9
-(9.5.4) 430.12 Section 9.5.4.2 emergency diesel engine fuel oil storage nd t f
.2 orage an rans er system (EDEFSS) does not specifically reference Regulatory Guide 1.137 and ANSI Standard N195 "Fuel Oil Systems for Standby Diesel Generators."
Indicate if you intend to comply with this regulatory guide and standard in your design of the EDEFSS; otherwise provide justification for noncompliance.
(SRP 9.5.4, Rev.
1, Part,, II, itern 12).
430.13 (9,5. 4) scuss what.precautfons have been taken fn the design of th f 1
o e
ue oil system in locating the fuel of 1 day tank and connecting fuel oil piping in the diesel generator room wfth regard to possible exposure to ignition sources such as open flames and hot surfaces.
(SRP 9.5;4, Part III, Item 6).
430.14 Discuss the rec precautionary ttwasures that w111 be taken to assure the quality'nd reliab111ty of the fuel o]l supply for emergency diesel generator operation.
Include the type of'uel oil, impurity and quality lfmitatfons as well as diesel index number or its equfvalent, cloud point, entrained moisture, sulfur, parti-culates and other del1 terfous insoluble substances; procedure for testing newly delivered fuel, per1odic sampling and testing of on-site fuel oil (including tnte~al betmen tests}, interyal of tice between periodic removal of conden-sate from fuel tanks and periodic system inspection.
In your discussion in-clude ref'erence to industry (or other) standard which wf11 be followed to assure a reliable fuel oil supply to the emergency generators.
(SRP 9.5.4, P4% U7, items 3 and 4}.
k
430-10 430. 15 Provide additional
'usti i
.(9.5.4) j ification to support your statement in section 9.5.4 4 that sufficient additional fuel can be delivered to the plant site by truck, rail or helicopter.
In your discussion include sources where diesel quality fuel oil is available and distances travelled from the source to the plant.
Also discuss how fuel oil will be delivered onsite under extremely-unfavorable environmental conditinns, including probable maximum flood conditions.
430.16 You state in section 9.5.4.2 that the diesel generator fuel oil (9.5.4) storage tank is provided W~th an individua1 f711 and vent 1ine.
Indicate where these lines are located (indoor or outdoor) and the height these lines are terminated above finished ground grade.
If these lines are located outdoors discuss the provisions made
<n your desfgn to prevent entrance of water into the storage tank dur-ing adverse environmenta1 conditfons.
430.17 Section 9.5.5 indicates that the function of the diesel generator coolin (9.5,5) r or coo ng water system is to dissipate the heat transferred through the:
- 1) engine water'acket,
- 2) combustion air (intake) cooler, and
- 3) engine turbo charger. 'rovide information on the individual component heat removal rates (but/hr), flow (lbs/hr) and temperature differential ('F) and the total heat removal rate required.
Also provide the design margin (excess heat removal capacity) included in the design of major components and subsystems.
(SRP 9.5.5, Part III, Item 1).
430.18 (9.5.5)
Provide the results of a failure mode and effects analysis t h
th t osow a
failure of a piping connection between subsystems (engine water jacket, ube oil cooler, service water system, combustion air (intake) cooler, and engine turbocharger cooler) does not cause total degradation of the diesel generator cooling water system.
(SRP 9.5.5, Part III, Item la).
430.19 You state
>n section 9.5.5.1 h
.5.1
.he diesel engine cooling wate~ is treated as appropriate to minimize corrosion.
Provide additional details of your proposed diesel engine cooling water system chemical treatment with regards to corrosion and organic fouling and d'discuss ow your proposed treatment complies with the engine manufacturers recommendations.
(SRP 9.5.5, Part III, Item lc)..
430. 20 (9.S.5)
Describe the instrmentation, controls, sensors and alarms provided f'r monitoring of the diesel ergine cooling water system and describe their function.
Discuss the testing necessary to maintain and assure a highly reliable instrumentation,
- controls, sensors, and alarm sys-
- tern, and ~here the alarms are annunciated.
Identify the temperature empera ure,
- pressure, level, and flow (where applicable) sensors which alert the operator when these parameters exceed the ranges recommended by the engine manufacturer and describe what operator actions are required during alarm conditions to prevent harmful effects to.the diesel en-gine.
Discuss the systems interlocks provided.
'(SRP 9.5.&, Part III, item lc).
/
430-12 430.2 1
The dtesel generators are requfred'to start automatfcally on loss of
~
~
all offsfte power'and fn the event of a
- LOCA,
'The diesel generator sets should be capable of oper atton at less than full load for extended periods wfthout degradatton of perfomince or relfabfltty, Should a
LOCA occur fifth avaflabflfty of offsfte power, dfscuss the desfgn provtstons and other parameters that have been consfdered fn the selectton of the diesel generators to enable them to run unloaded (on'tandby) for extended perfods wfthout degradatfon of engfne performance or relfabflfty.
Expand your PSAR/FSAR to fnclude and explfcttly deffne the capabflfty of your design fifth regard to thfs requtrement, (SRP 9.5.5, Part III, Item 7}
430.~2'ou state in secti (9.5.5)
'on 9.5.5.2 each d>esel engine cooling water syste m is provided with a surge tank to provide for system expansion and for venting air from the system.
In addition to the items mentioned, the surge tank is to provide for minor system leaks at pump shafts
- seals, valve stems and other components, and to maintain required NPSH on the system circulati'ng pump.
Provide the size of the expansion tank and location.
, Oemonstrate by analysis that the expansion'ank size will be adequate to maintain required pump NPSG and make up water for seven days continuous operation of the diesel engine at full rated load without makeup, or provide a seismic Category I, safety Class 3 make up water Supplg !o !he expansion tank..
430.23 Provide the source of power for. the diesel engine motor driven recirculation (9.5.5) jacket water pump and electric jacket water heater.
Provide the motor and electric heater characteristics, i.e., motor hp., operating voltage, phase(s),
frequency and kw output as applicable.
Also include the pump capacity and discharge head.
Revise the FSAR accordingly,
'9.5.6) 430.24 Provide a df'scussfon of the measures that have been taken fn the design of the standby dfesel generator afr starting system to preclude the fo~ling of the afr start valve or Alter 'with moisture and contaminants such as ofl carryover and rust.'SRP 9.5,6, Part III, ftem 1),
430. 25, (9.5,6)
Qescrfbe the instrumentatfon,
- controls, sensors and alarms pro-vided for monftorfng the diesel engine afr starting system, and describe their function.
Describe the testfng necessary to mafn-tain a highly reliable fnstraaentatfon, control, sensors and alarm system and where the alarms are annunciated.
Identify the temperature, pressure and level sensors whfch alert the operator when these parameters exceed the ranges reccmmended by the engine manufacturer and describe ary operator actions required during alarm conditions to prevent harmful effects to tl e diesel engine.
Discuss system interlocks provfded.
Revise your FSAR. accordingly.
, (SRP 9.5.6, Part III, item 1).
430.26 Provide the source (9.5.6)
Cy'0485 compressors operating voltage, accordingly.
of pair for the diesel engine air starting and motar. characteristics, f.e., motor hp, phase(s),
and frequency.
Revise your FSAR
.430-14 430.27
'(9.5.7)
For the diesel engine lubrfcatfon system fn Section 9.5.7 provide the following information:
- 1) define the temperature differentials, flow
- rate, and heat removal rate of the interface cooling system external to the engine and verify that these are fn accordance with recomnendatfons of the engine manufacturer;
- 2) discuss the measures that will be taken to maintain the required quality of the oil, including the inspection and
, replacement when ofl quality fs degraded;
- 3) describe the protective features (such as blowout panels) provided to prevent unacceptable crankcase explosion and to mitfgate the consequences of such an event; and 4) describe the capability for detection and control of system leakage.
(SRP 9.5.7, Part II, Ttens Sa, Bb, 8c, Part III, Item 1.)
430.28 (9.5.7)
%hat measures have ave been taken to prevent entry of deliterious materfaIs into the engfne 1ubricati fl on o system due to operator error during recharging of lubrfcati il ng o or normal operation.
(SRP 9.5.7, Part III> Iten lc}.
430.29 Describe the instrumentation,
- controls, sensors and alarms pro-.
(9.5.7) vided for monitoring the diesel engine lubrication ofl system and describe their function.
Gescrfbe the testing necessary to maintain z highly reliable fnstruaentatfon, control, sensors and alara s)stem and where the alarms are annunicfated.
Identify the temperature, pressure and level sensors whfch alert the OPCt8tOt when these parameters exceed the ranges recaaaende'd by r
l the Ng,nc aenufacMrer and describe any operator action required during alarm conditions to prevent harmful effects to the diesel engine.
Discuss systems fntarlocks provfded.
Revise your FSAR
'ccor'dingly.
(SRP 9.5.7, Part III, ftea 1e).
430,30 Provide the source of power for the diesel engine prelube oil pump, (g.s.7) and lube oil circulation heater.and used lube oil tank transfer
- pump, and motor characteristics, i.e., motor hp, operating voltage, phase(s) and frequency.
Also provide the pump capacity and discharge head.
Revise your FSAR accordingly.
430.31 (9.5.7)
RSP Several fires have occurred at some operating plants
$ n the area of the dieseI
'engine exhaust aanifo1d and inside the turbocharger housing which have resulted in equipment unavailability.
The fires were started from lube oil leaking and accumulating on the engine exhaust manifold and accumulating and tgnittng inside the turbocharger housing.
Accumulation of lube oil tn these areas, on some engines, ts apparently caused from an excessively long prelube pertod, generally longer than five minutes, prior to manual starting of a diesel generator, This condition does not occur on an emergency start since the prelube period is minimal.
Mhen manually starting the diesel genirators for any reason, to minimize the potential fire hazard and to tmprove equipment availabiltty, the preIube period should be'limited'to a maximum of three to five minutes unless otherwise recoamended by the diesel engine manufacturer, Confirm your compliance. with this requirement or provide your Justification for requiring a longer prelube time tnterval prior to manual starting of 4h6 debase) generators, Provide the pr elube ttme 'interval your diesel engine will be exposed to prior to manual start.
430-16 430,32 (9.5.8)
Describe the instrumentationcontrols, sensors and alarms provided
$ n the design of the diesel engine combustion air intake and exhaust system which alert the operator when parameters exceed ranges recommended by the engine manufacturer and describe any operator action required during alarm conditions to prevent harmful effects to the diesel engine.
Discuss systems interlocks provided.
Revise your FSAR accordingly.
(SRP '9.5.8, Part III, item 1
5 4).
430.33 (9.5.8)
Provide the results of an analysis that denenstrates that the function of your diesel engine air intake and exhaust system design will not be degraded to an extent which prevents developing full engine rated power or cause engine shutdown as a consequence of any meteorological or accident condition.
Include in your discussion the potential and effect of fire extinguishing (gaseous) medium, recirculation of diesel combustion products, or other gases that may intentionally or accidentally be released on site, on the performance of the diesel generator.
(SRP 9.5.8, Part III, item 3).
430. 34 (9.5,8)
Nscuss the provisions made in your design of the diesel engine combustion air intake and exhaust system to prevent possible clogging, during standby and in operation, from abnormal climatic conditions (heavy rain, freezing rain, dust storms, ice and snow) that could prevent operation of the diesel generator on demand.
(SRP 9.5.8, Part III, item 5),
0
Z30.35 (g.s.s)
Qew by aoal~fs that t yoteatfal tin 5a ~.dfesel generator bufld-fng together wfth a sfnngle faf1ure of the ffre protection system wf11 not degrade the qualfty of the dfesal combustion afr so that the remainfng dfesel wfll be able to p~fde full rated parer.
O30.36 (9.s.s)
Experfence at some operatfng plants has shown that diesel engines have failed to start due to accumulatfon of dust and other delfterfous material on electrical equipment associated with starting of the diesel generators (e.g., auxflfary relay contacts, control switches - etc.).
Oescrfbe the provisions that have been made fn your diesel generator bufldfng design, electrical starting system, and combustion afr and ventilation afr intake design(s) to preclude this condition to assure availability of the diesel generator on demand.
Also descrfbe under normal plant operation, what procedure(s} will be used to mfnfmfze accumulatfon of dust fn the diesel generator room; specifically addr ess concrete dust control.
In your response also consider the condition when Unit 1 is in operation and Unit '2 is under construction (abnormal generation of dust).
430.37 (10.1) provide a general
@scusshe ef the MtIarfa and bases K C!ie varfous.
steam and condensate fnstrumentatfon systans'fn section 10.1 of the F5AR.. The FSAR should dffferentfate be&een normal operation fnstrun>>ntatfon and requfred safety fnstruaentatfce.
,N
430-18 430.38 (10.2)
Expand your discussion of the'urbine speed control and overspeed protection system.
Provide additional explanation of the tur bine and generator electrical load following capability for the tur-0bine speed control system with the aid of system schematics (including turbine control and extraction steam valves to the heaters).
Tabulate the individual speed con.rol protection devices (normal emergency and backup),
the design speed (or range of speed} at which each device begins operation to perform its protective function (in terms of percent of normal turbine operating speed).
In order-to evaluate the adequacy of the control and overspeed protection system provide schematics and include identifying numbers to valves and m
h
(
an mec anisms (mechanical and electrical) on the schematics.
Describe t '1, cri e in etail, with references to the identifying numbers, the sequence of events in a turbine trip including response
- times, and show that the tunbine stabilizes.
Provide the results of a failure mode and effects analys'is for the overspeed protection systems Show that a single steam valve failure cannot disable the turbine oyer-speed trip from functioning.
(SRP 10.2, Part III, items 1, 2, 3
and 4).
430. 39 (10.2)
The FSAR discuspes th>> lain steam stop and contro1, and reheat stop and intercept va1ves.
Show that a single fai1ure of any of tent Shave valves cannot disable the turbine overspeed trip 'func-V
- CEonN, (SRP 10.2, Part III Iten 3).
4
0 430-19 430.40
. (10.2)
Expand your discussion of the inservfce inspectton program for throttle-stop, control, reheat stop and interceptor steam valves to include inspection times and the capability for testing essential components during turbine generator system operation.
(SRP 10.2, Part III, items 5 and 6).
430.41 (1.0.2}
Discuss the effects of a high and moderate energy piping failure or failure of the connection from the low pressure turbine to condenser on nearby safety related equipment or systems.
Discuss what protection will be provided the turbine overspeed control system equipment, electrical wiring and hydraulic lines from the effects of a high or moderate energy pipe failure so that the turbine overspeed protection system will not be damaged to preclude its safety function.
(SRP 10.2, Part III, Item 8}.
430. 42 (10.2)
In section 10.2.3.6
ou discuss in-service inspection and exercis-ing of the main steam turbine stop and control and reheater stop and intercept valves.
You do not discuss the in-service inspection, testing and exercising of the extraction steam valves.
Provide a
'etail description of:
- 1) the extraction steam valves, and 2) your inservice inspection and testing program for these valves.
Also provide the time interval between periodic valve exercising tc assure the extraction steam valves H)l cTose on turbine trip.
h
430-20 430.43 Desc~ibe with the a'id of drawings the bulk hydr to (10.2) rogen s
rage facility including its location and distribution sys em.
Include he protective measures considered in the design to prevent fires and ex"losions during operations such as filling and purgino the generator, as well as during normal operations.
430.44 (10.2)'ect>on 10.2.1.3 references the CESSAR turbine generator interface requirements of section 5.1.4 and 7.2.3.
The CESSAR FSAR sections 5.1.4 and 7.2.3 do not contain any turbine generator interface requirements.
Clarify this incon-'istency, provide the CESSAR interface requirements and an evaluation of how you are meeting those requirements.
430.45 (10,3)
As explained in issue No.
1 of ttUREG of 0138, credit is taken for all valves downstream of the Main Steam Isolation Valve (HSIV) to limit blowdown of a second steam generator in the event of a steam line break upstream of the HSIY.
In order to confirm satisfactory per-I formance following such a steam line break provide a tabulation hand descriptive text (as approprfate) tn the.FSAR of'11 flee paths that branch off the aain steam )Ines bebeen the %IV's and the turbine stop valves';
For each fler path ortgtnating at the main steam 1<nes, provide the follMng $nforaat$ on:
a)
System identiQ~tion')
Maximan steam flow 'fn pounds per bour,
- 4) f~ Of shut-off valve(s) d)
S',.1e of valveb)
e)
Qalfty of the valve(s}
f)
Desfgn code of the valve(s}
g)
Closure tfue of the valve{s}
hf jtctuatfon iechanfsm of the valve{s} (f,e 5olenofd operated, actor operated, afr operated diagram valve, etc.}
,f) lhtfve or paar source for the valve actuatfng eechanfsm In the event of the postulated uccfdent, temfnatfon of steam flee fram a11 systettts fdentfffed above, except those that can be used for ar(tfgatton of the accfdent, fs requfred to brfng the reactor to a safe cold shut-down.
For these systens descrfbe what desfgn features have been fncorpor ated to assure closure of the sterna shutofff'a>ver},
Descr fbe what operator actfcee (tf any} art reprfred.
lf the system that can be used for arltfgatfon of the accfdent are no". avatlable or'A.fsfon fs made to use other means to shut down the reactor descrfbe how these systens are secured to assure posftfve steam shut-off, Descrfbe what operator actfons (4t any) are requfred, If'ny of the requested fnfometfon fs present1y fnclvded fn the FSQ text, provfde only the references where the fnformatfon aalu be found,
430-22 430.46 Provide a-tabulation in your FSAR showfng the physical characterfstfcs
'10.4.1}
and performance requirements of the main condensers.
In your
~ tabulation include such'items as; 1) the number of condenser
- tubes, material and total hea) transfer surface,
- 2) overall dimensions of the condenser,
- 3) neaber of oauses,
- 4) hot well capacity,
- 5) special de ign features,
- 6) minimum heat'transfer,
- 7) normal and'maximun steam flows, 8) normal and maximum cooling water temperature,.
9} normal and maximum exhaust steam temperature with no turbine by-pass flow and with aaxiarwr turbine by-pass flow,
- 10) limiting oxygen content in the condensate in cc per liter,.
and 11) other pertinent data.
(SRP 10.4.1, Part III, item 1).
47 30.
Oiscuss the measures taken; 1) to prevent loss of vacuum, and (10,4.1)
- 2) to prevent corrosion/errosion of condensertubes and components.
(SRP 10.4.1, Part III, fterrr 1).
(10.4.1 )
430.48 Indicate and describe the means of detecting and controlling. radioactive leakage into and out of the condenser and the means for processing excessive amounts.
(SRP 10.4.1, Part EEL, item 2}.
(10.4.1) 430.49 Discuss the measures taken for detecting controlli d
r ing an correcting condenser cooling water leakage into the condensate
- stream, (SRp 10.4.1, Part EEI, item 2) 430.50 fry Cdctfon 10.4.1.4 o'u h
(10.4.1)
..1.4 you have dfscussed tests and fnitia1 ffe1d fn-spectfon but not the frequency and extent f f n
o nservice fnspection of the main condenser.
Provide thfs information fir the FSAR.
(SRP 10.4.1, Part II).
C
430-23, 430.
51 Indicate what desi n
(10.4.1) gn provisions have been made to preclude failures of condenser tubes.pr components from turbine by-pass blowdown or.
other high temperature drains into the ccndenser shell.
(SRP 10.4.1, Part III, item 3).
(10.4.1,)
430 52 Discuss the effect of Toss of main condenser vacuum o
th cuum on e operat on of the ma{n steam ksolatfon valves (SRP 10.4.1, Part III, ftem 3).
430. 53 Provide additional description (with the aid of drawings) of th t bi (10.4,4 )
e ur ne by-pass valves and associated instrumentation and controls.
In your discussion include the number, size, principle of operation, construction, set points, and capacity of each valve and the malfunctions and/or.
modes of failure considered in the design of the turbine by-pass system.
(SRP 10.4.4, Part III, Item 1.)
430.54 Provide the results of an analysis indicating that failure of the (10.4,4) turbine by-pass system high energy line will not have an adverse effect or preclude operation of the turbine speed control system or any safety related components or systems located close to the turbine by-pass system.
(SRP 10.4.4, Part III, item 4).
430. 55 'n section 10.4.4.4 you. have discussed tests and f ftf 1 ff ld (10.4.4) n a
e inspection but not the frequency and extant of fnservfce testing 8hd knsplct<on of the turbine by-past sys.em.
Provide this fnfor-
~
I
!tlat{on {n the FSAR.
(SRP 10.4.4, Part II).
Cy
0
. 430-24 (10.4:4) 430.56 Section 10,4.4 of your FSAR refers to section 10.4 4 f CESSAR 0
for additional discussion of the turbine bypass system.
Your turbine bypass system di ffers from the one discussed 'in CESSAR, in that two of your bypass valves dump to atmosphere while in CESSAR they do not.
Provide a discussion to show that your system meets the eleven (11} design bases stated in section 10.4.4.1 of CESSAR.
450-1 450.0 ACCIQENT EVALUATION BRANCH 450.1 (3.:.1.4, PYNGS) 450.2 (3.5.1.4,
~ PVNGS) 450.
"'6.4, PVHGS}
450.4 (6.4, PVNGS)
]50.5 PVNGS}
450.6 (6.5.2 VVN0S')
450.7 (6.5.2, PYNGS)
Prov>de the locations of all safety-related equipment not contained witirirr reirrforced corrcrote buildings or structures.
Provide the structural compositiorr of all walls and roofs of buildings housing safety-related equipment, as well as the bui lding locations.
Discuss ter<< sizes and directional orienta-tions of any openings in these buildings.
Oescribe the protection of the cnrrtrol room air intakes and diesel generator exharrst piiros from tornado-generated mrssiles.
In your description of the control room's protective features, provide the time interval betweerr the time the chlorine concen-tration exceeds 5 ppm at the isolation,dampers and the time the darnpers are completely closed.
List the areas, equiprrrent and materials to which the control room operator has access during errrergency operation, i...
during the time the control room is serviced by the emergency ventilation systerrr.
In your analysis of toxic gas prot.ection for control room personnel, provide the number and type of respiratory devices, the type of operator training for r.espiratory
- use, the estima-ed time for donning or deployirrg the equipment, the length of time the equipment can be used, and the equipment testing arid maintenance procedures.
On page 6.5-27 of the PVNGS FSAR, it is stated that the post-LOCA sump pH shall be raised to a minIrrrum of 7.0.
It is not cl that the pH, by itself, is hiqh enough to prevent iodine evolu-no c ear tion from the sump.
Explain frow evolution of, iodine from the post-LOCA sump will be prevented,'r kept to a very low level.
Pl ease provide spray nozzle perfonnance data (spray droplet
- pattern, drop size distributinrr) for Spraco 1?071412 and l7651308 nozzles.
450.8 (6.5.2p Pi NGS)
The discussion
'on pages 6.5-8 arrd 6.5-9 implies that 100" of the contairrment, net free vnlrrrrre (abuve 100 ft. elev.) is sprayed.
State whetlrer this inrplication is true and provid j stification for the si~ray cnv<<rages assrmred in your analysis.
U f
i e
450-2 450. 9 (15.1.5(A),
'VHGS'nd 15.1.".
Ill.6.5, P Yt>GS 15.6.4, and 15.6.5 CESSAR) 450.11 (15.7.3.3 and 15.7.3.4; PYNGS)
Justify your conclusion that the radiological releases from main steam line failure outside containment are no more adverse than the releases from small steam line breaks outside contain-ment and upstream of the main steam isolation valves (CESSAR Section 15.1.4.2).
Also, provide the assumptions and dose tainm calculations for both the main steam line failure o ts'd ent and the small steam line break outside containment i ure ou si e con-upstream of the main steam isolation valves.
In evaluating the double-ended break of the letdown line outside containment, provide the following:
(1) sumnary of primary system's iodine activity, including the potential increase in iodine release rate (iodine spiking) above the equilibrium value during the. accident and its effect on the accident doses; and
'2) valve closure time and maximum permissible leakage rate of the letdown line isotation valve.
In evaluating the radioactive liquid waste system leak or failure, provide data, assumptions and methodology used in analyzing the radiological consequences of fission gases released to the atmosphere.
451-1 ACCIDENT EVAlUATION BRANCH Appendix E to 10 CFR Part 50 outlines requirements for Emer enc fur th Planning and Preparedness.
NUREG-0737 and NUREG-Q654 er guidance on the requirements which include an upgraded meteorological measurements program.
Provide a description of your upgraded program to meet these requirements.
Include details about any new instrumentation to be installed, the atmospheric transport and diffusion model used in the dose assessment methodology, and data availability to emer enc response organizations.
46nl 460.0 EFFLUENT TREATMENT SYSTEMS BRANCH 460-1 (1.8)
(Ii. 2)
(11.3)
(11.4)
Provide a table under Section 1.8 comparing the design features of the liquid, gaseous and solid radwaste systems wi th the positions of Regulatory Guide 1.143 (July 1978),
"Design Guidance for Radioactive Haste Management
- Systems, Structures, and Components Installed in
'light-Mater-Cooled Nuclear Power Plants."
For each item. for which an'exception is taken, the applicability of the proposed exception hould be justified. If sufficient justification is provided in other sections for the individual items, cross references to those sections will be adequate.
460.2 (3.2)
Include Sections for Effluent Radiation Monitors and Process Radiation Monitors in Table 3.2-1 of the Final Safety Analysis Report (FSAR),
which lists gualf ty Classification of Structures, Systems and Components.
460.3 (1.8, 6.5)
In Section 1.8 of the FSAR which deals with 'Conformance to NRC Regula-tory Guides',
reference is made to Regulatory Guide 1.52, Rev.
0 (June 1973) and Rev.
1 (July 1976) versions.
Since Regulatory Guide 1.52, Revision 2, (March 1978),
"Design, Testing and Maintenance Criteria for Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Hater-Cooled Nuclear Power Plants" has replaced the earlier versions, comparison should be made of the design features'nd fission product removal capability of ea h
ESF fflter system to applicable positions detailed in'Regulatory Guide 1.52,
g4 E
460-2 Rev. 2.
For each item for which an exception is taken, the accept-ability of the proposed design should be, justified.
For example, if as" stated under Sectio~ 1.8, demi sters are not provided for the fuel build-ing ESF Ventilation System, explain how relative humidity will be controlled so-as'not to exceed 70%.
Likewise, if as stated under Section 1.8, IE alarms or recorders for pressure drops or flow rates for the ESF Ventilation Systems are not provided, describe the form in.
which this information is available in the control room, e.g., digital.
readout of pressure drop and/or flow rate, type of alarm, such as
'high'r
'low', visual or audible, etc.
I 4
Describe provisions for ensuring that the limits for radioactive concen-trations are not exceeded in the demineralized water system and conden-sate storage facilities.
Address the Followina concerns on Sections 9.3 and 11.5 of the FSAR:
1)
Provide continuous process monitoring capability for the Spent Fuel Pool and Refueling Pool Treatment Systems.
Clarify whether discrete sample analyses pr ovisions are available for both the high and low TOS holdup and monitor tanks.
Describe the provisions for monitoring concentrate monitor tank activi ties.
4)
Describe the process sampling provisions for'rab sampling iodine in fuel storage area vent system, radwaste area vent system and
460-3 the evaporator vent system (these are required by Standard Review Plan, Section>>.5, Rev. 2, "Process and Effluent Radiological Monitoring and Sample Systems",
See Table 1A).,
460.6 (9.4)
(>>.3)
Provide a table comparing the design features'and radioactivity removal capability of each normal ventilation filter system to each position de-tailed in Regulatory Guide 1.140, Rev.
1 (October 1979),. "Design, Testing and Maintenance Criteria for Normal Yentilation Exhaust System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants".
For each i tem for which a exception i s taken, the appl ic-ability of the proposed exception should be justified.
460.7 (11.1)
Provide the data required for radioactive source term calculations for
'MRs using the format given in Chapter 4 of HUREG-0017, April 1976, "Calculation of Releases of Radioactive Materials in Gaseous and Liquid Effluents from Pressurized Mater Reactors."
460.8
(>>.2)
(9.3)
Section 9.3 of the FSAR states that the turbine building liquid wastes will be pumped to the evaporation pond if the effluent quality will meet.
the standards for pH, conductivity and radioactivity.
Explain how tests will be conducted for the radioactivity of these wastes, and also give information on the ultimate disposal of the wastes that get col-lected in the evaporation pond.
A
460-4 460.9
(>>.2)
Describe the provisions for preventing overflow and/or containing the f
tank contents in the event of failure of the reactor makeup water tank. ~
460.10
(>>.3)
Information on hydrogen and oxygen gas analyzers is inadequate.
Since the system is not designed to withstand a hydrogen explosion,'at least one gas analyzer should be provided, operating continuously between the compressor and the storage tanks, with automatic control functions to prevent the formation or buildup of explosive hydrogen-oxygen mixtures
>n the storage tanks.
Annunciating alarms should be provided locally and in the control room (see the acceptance criteria of the Standard Review Plan, Section 11.3, Rev.
1, "Gaseous Waste Management Systems" ).
Also, provide information such as the number of sample points, sampling frequency at each point, alarm provi sions and control features for the described sequential monitoring system.
460.11 (11.3)
In Table 11.3-5, Krypton-89 estimated input concentration to the gaseous radwaste system from the reactor drain tank is shown as 4.5 x 10 uCi/cm This appears to be too high when compared to values contained in NUREG-0017 and should be confirmed or corrected.
460.12 (11.3)
Describe the provisions included in the design. of the gaseou's waste tr'eatment system to stop continuous leakage'aths (see the requirement stated under Acceptance Criteria II.3 of SRP Section 11.3, Rev, 1).
460-5 460.13 Comparison with NUREG-0017 sugests,that Table 11.3-6 of the FSAR on annual releases of gaseous effluents containes some errors.
For
- example, estimates of noble gas to be released frcm the containment building and Xe-133 to be released from the auxiliary/ radwaste buildings are lower than would be expected., This table should be reeval ua ted a nd corrected if approp r iate.
460. 14
(>>.3)
The system design provides for the return of the flashed steam frcm the blowdown flash tank to the secondary system via the Ho.
4 feedwater heaters (see Section 10.4.6.2.2 of the FSAR).
- Also, a charcoal/HEPA filtration system is provided for the main condenser air removal system exhausts (see Table 11.3-7 of FSAR).
Since these two augments have already been included in the system design, they should be ex-cluded from the cost-benefit analysis (see Tables 58-8 through 58-11 of the Environmental Report) as per I.d of Appendix I to 10 CFR Part 50.
460. 15 (11.4)
Clarify whether wastes collected in the evaporation pond will be an additional input to the Solid Radwaste System (SRS) input volumes.
If so, provide estimates of. the volumes and activities of these wastes.
'460.16 (11.4)
Explain how the SRS output activities provided in Table 11.4-6 for evaporator concentrates,,
spent resin beads, cartridge filters and
460-6 disposable crud filters are related to their corresponding input activities provided in Table 11.4-2.
460'7 (12.2) provide radionuclide inventories of the refueling water tank and the reactor. makeup water tank referred to in FSPR Section 12.2.1.7 (Section 12.2.1.7 states that these tank inventories are described in Section 12.2.1.1.5.1;
- however, these are not described in Sec-.
tion 12.2.1.1.5.1).
0 Il dg d'